Utne v. Home Depot U.S.A., Inc., 3:16-cv-01854-RS. (2019)
Court: District Court, N.D. California
Number: infdco20191115863
Filed: Nov. 14, 2019
Latest Update: Nov. 14, 2019
Summary: JOINT STIPULATION AND [PROPOSED] ORDER TO EXTEND EXPERT DEADLINES, DEFENDANT'S DECERTIFICATION MOTION BRIEFING DEADLINES, PRETRIAL CONFERENCE AND TRIAL DATE AS MODIFIED BY THE COURT RICHARD SEEBORG , District Judge . JOINT STIPULATION This Joint Stipulation to extend expert deadlines, Defendant's decertification motion briefing deadlines, pretrial conference and trial date is made by and between Plaintiff John Utne ("Plaintiff") and Defendant Home Depot U.S.A., Inc. ("Defendant"), t
Summary: JOINT STIPULATION AND [PROPOSED] ORDER TO EXTEND EXPERT DEADLINES, DEFENDANT'S DECERTIFICATION MOTION BRIEFING DEADLINES, PRETRIAL CONFERENCE AND TRIAL DATE AS MODIFIED BY THE COURT RICHARD SEEBORG , District Judge . JOINT STIPULATION This Joint Stipulation to extend expert deadlines, Defendant's decertification motion briefing deadlines, pretrial conference and trial date is made by and between Plaintiff John Utne ("Plaintiff") and Defendant Home Depot U.S.A., Inc. ("Defendant"), th..
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JOINT STIPULATION AND [PROPOSED] ORDER TO EXTEND EXPERT DEADLINES, DEFENDANT'S DECERTIFICATION MOTION BRIEFING DEADLINES, PRETRIAL CONFERENCE AND TRIAL DATE AS MODIFIED BY THE COURT
RICHARD SEEBORG, District Judge.
JOINT STIPULATION
This Joint Stipulation to extend expert deadlines, Defendant's decertification motion briefing deadlines, pretrial conference and trial date is made by and between Plaintiff John Utne ("Plaintiff") and Defendant Home Depot U.S.A., Inc. ("Defendant"), through their respective counsel of record, with reference to the following facts:
1. Both parties have designated experts for trial. Plaintiff designated three experts, and Defendant designated one expert.
2. Defendant has produced a voluminous quantity of material in support of Defendant's expert Robert Crandall's report, including 30 hard drives containing video footage of Home Depot stores, and 15,000 pages of documents. Defendant relies on Defendant's expert Robert Crandall's report in support of their motion to decertify.
3. Plaintiff's experts need time to review and analyze this voluminous material.
4. Plaintiff's expert Dr. Jon Krosnick has produced a several hundred page report and voluminous production of documents and data that Defendant's expert needs time to review and analyze.
5. Accordingly, the parties believe the current expert discovery schedule is not feasible. The parties and their experts need additional time to review and analyze the material produced in connection with the experts, and for expert depositions, than is permitted under the current deadlines. In addition, because the expert discovery relates to defendant's pending motion for decertification, and such discovery and the decertification motion will impact the parties' preparation for the pretrial conference and trial, the parties believe it is necessary to continue the current expert discovery, all pretrial deadlines, and the trial date by 60 days.
6. Thus, the parties agree to extend the deadlines and dates in this case by approximately 60 days and respectfully request that the Court adopt the below proposed revised case schedule.
EVENT PROPOSED DATE
Rebuttal and Supplemental Expert Designation Deadline January 31, 2019
Plaintiff's Opposition to Defendant's Decertification Motion Deadline January 31, 2019
Defendant's Reply ISO Defendant's Decertification Motion Deadline March 6, 2020
Last day for hearing pretrial motions February 20, 2020
March 13, 2020
Completion of Expert Discovery
Hearing Date for Defendant's Decertification Motion Deadline April 2, 2020 at 1:30 p.m. or
as soon thereafter as the
Court is available
June 24, 2020
Pretrial Conference
August 3, 2020
Trial Date
7. To date, the following deadlines in this action have been modified: Stipulation to Continue Initial Case Management Conference and Order granting same (Dkt Nos. 17 and 18); Stipulation to Continue Class Certification Briefing and Hearing and Order granting same (Dkt Nos. 35 ad 36); Stipulation to Continue Briefing and Hearing and Order granting same (Dkt Nos. 110 and 111); Defendant's Motion to Enlarge Time to Oppose Plaintiff's Motion for Partial Summary Judgment and Order granting same (Dkt Nos. 122 and 124); Stipulation to Extend Plaintiff's Deadline to Oppose Motion for Partial Summary Judgment and Order Granting Same (Dkt 130); Stipulation to Extend Expert Deadlines, Defendant's Decertification Motion Deadline, Pretrial Conference and Trial Date (Dkt 144); Stipulation to Extend Expert Deadlines, Decertification Motion Deadline, Pretrial Conference and Trial Date. (Dkt 151) and Stipulation to Set Briefing Schedule and Hearing Date for Defendant's Motion to Decertify (Dkt 155).
IT IS SO STIPULATED.
Pursuant to Civil Local Rule 5-1(i)(3), the filer attests that concurrence in the filing of this document has been obtained from each of the above signatories.
[PROPOSED] ORDER
GOOD CAUSE APPEARING, IT IS HEREBY ORDERED that the following deadlines and hearing date are entered:
EVENT PROPOSED DATE
2020
Rebuttal and Supplemental Expert Designation Deadline January 31, 2019
2020
Plaintiff's Opposition to Defendant's Decertification Motion Deadline January 31, 2019
Defendant's Reply ISO Defendant's Decertification Motion Deadline March 6, 2020
Last day for hearing pretrial motions February 20, 2020
March 13, 2020
Completion of Expert Discovery
Hearing Date for Defendant's Decertification Motion Deadline April 2, 2020 at 1:30 p.m. or
as soon thereafter as the
Court is available
June 24, 2020
Pretrial Conference
August 3, 2020
Trial Date
Source: Leagle
